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INVISIBLE HAZARD KILLS AGAIN

Wednesday, January 18, 2012

Roco Director of Training/Chief Instructor, Dennis O’Connell reviews the importance of following OSHA safety standards for confined space entry, no matter how many times workers have entered the space. The take away? With confined spaces…It’s NEVER old hat! The importance of preplanning confined space entries and identifying “potential hazards ”should be old hat by now. Yet every year we are still killing entrants and rescuers in confined spaces.

In the story below, we have one very lucky rescuer, but this very easily could have been a multi-fatality event.

Atmospheric Hazards Continue to Claim Lives in Confined Space Entry Scenarios

The importance of preplanning confined space entries and identifying “potential hazards” should be old hat by now. Yet every year we are still killing entrants and rescuers inconfined spaces.  In the story below, we have one very lucky rescuer, but this very easily could have been a multi-fatality event.

It’s always important to remember that each entry stands alone. Each and every time a space is entered, we need to:

(a) identify potential hazards;

(b) eliminate or control them, when possible;

(c) use proper PPE; and,

(d) have an EFFECTIVE Rescue Plan.

Otherwise, as in this story, we will lose or injure workers as well as those attempting the rescue.

Start from scratch and treat each entry like it’s the first time you’re entering the space – it could save your life.

Keep in mind, the history of a space really has nothing to do with the current entry. We’ve all heard people say, “We do this all the time, and we’ve never had a problem!” Or, “We’ve entered this space a thousand times and the air is always good!” Remember this… IT DOES NOT MATTER!! This entry has nothing to do with the last.

As you read of yet another unfortunate incident, let it be a reminder to those of us who make entries or do rescues from confined spaces – do not let your guard down, do not get complacent…it could be deadly. Atmospheric hazards are still one of the leading ways that people are dying in confined spaces. Because humans are visually oriented by nature, if we can see a hazard, we’ll protect ourselves from it. However, if we can’t see it, we tend to assume it’s safe. OSHA’s 1910.146 PRCS standard and others were developed for a reason… people were making tragic mistakes and dying in confined spaces. These standards and guidelines are written so we don’t make the same mistakes.

OSHA FINES UTILITY FIRM $118,580 FOLLOWING WORKER’S DEATH

OSHA has cited a contracting and utilities company for two willful and two serious safety and health violations following the death of a worker at the company’s Texas facility. Proposed penalties total $118,580. An inspection was initiated by OSHA on June 28 in response to a report that employees working on a new sewer line were exposed to inhalation of a hazardous chemical. One employee who entered a manhole to remove a plug in order to flush out accumulated debris became overwhelmed by toxic fumes and died. Another employee was hospitalized after attempting to rescue his co-worker.

The willful violations are for failing to test for atmospheric conditions and provide adequate ventilation and emergency retrieval equipment prior to entry into a manhole.

The serious violations are failing to provide or require the use of respirators as well as conduct an assessment to determine the potential for a hazardous atmosphere where oxygen deficiency, methane, and/or hydrogen sulfide were present or likely to be present.

“The company failed to ensure that proper confined space entry procedures were followed,” said Jack Rector, OSHA’s area director in Fort Worth. “If it had followed OSHA’s safety standards, it is possible that this tragic incident could have been prevented.”
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RESCUE IV-ADVANCED SCENARIOS

Wednesday, December 07, 2011

We’ve had so many requests for “advanced-level scenario training” that we’ve added Rescue IV to our 2011 schedule. You can add new techniques to your rescue toolbox while putting your problem-solving skills to the test.Challenging confined space and high-angle evolutions, including Roco’s“Yellow Brick Road” multi-station scenario, will give rescuers and rescue teams the most realistic rescue experience possible. This 40-hour course will challenge participants in a wide variety of confined space and high angle rescue scenarios.

RESCUE IV – ADVANCED SCENARIOS (40 hours)
Prerequisite: Rescue I-Plus or Industrial I/II

Challenging confined space and high-angle evolutions, including Roco’s “Yellow Brick Road” multi-station scenario, will give rescuers and rescue teams the most realistic rescue experience possible. This 40-hour course will challenge participants in a wide variety of confined space and high angle rescue scenarios.Advanced problem-solving skills and additional techniques will equip rescuers to function more effectively in time-critical emergency situations. This 40-hour course will challenge individual rescuers and rescue teams in a wide variety of confined space and high angle rescue scenarios. These scenarios will increase in complexity to include simulated IDLH and non-IDLH atmospheres, using both SCBA and SAR air equipment. For training conducted at Roco’s training facility, practice scenarios will be completed in all six (6) types of representative confined spaces. At other sites, the number of types completed will depend on the availability of practice spaces.This course will provide documented confined space practice scenarios in accordance with OSHA 1910.146 and as referenced in NPFA 1006.

OSHA 1910.146(k)(2)(iv)

Ensure that affected employees practice making permit space rescues at least once every 12 months, by means of simulated rescue operations in which they remove dummies, manikins, or actual persons from the actual permit spaces or from representative permit spaces. Representative permit spaces shall, with respect to opening size, configuration, and accessibility, simulate the types of permit spaces from which rescue is to be performed.

NFPA 1006 A.3.3.38 Confined Space Type

Figure A.3.3.38* shows predefined types of confined spaces normally found in an industrial setting. Classifying spaces by “types” can be used to prepare a rescue training plan to include representative permit spaces for simulated rescue practice as specified by OSHA. (*Roco Confined Space Types Chart)
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Confined Space Fatalities…a closer look at the numbers

Tuesday, November 01, 2011

At some point during just about every Roco CSRT Rescue Stand-By job, someone will ask us why we are there. After we tell them that we’re there to make sure all the workers go home safely (and explain some of the basic requirements of OSHA’s 1910.146 regulation), they will normally add, “Well, we’re glad you’re here!”When asked how often we have to do a rescue, we’ll tell them that it’s not often – because our goal is to make sure a rescue never has to happen. With careful pre-planning and proper entry procedures, an entry rescue should not be needed. 

As we all know, however, things go wrong – especially in a confined space. And that’s when a Stand-by Rescue Team can make all the difference in the world – especially to the worker(s) in the hole.

With a facility that plans for confined space entry and routinely follows all safety precautions, employees just might not realize how common these confined space emergencies can be. With that in mind, we decided to do some very basic analyses of statistics from the Department of Labor. In looking at permit-required confined space incidents from 2005 through 2009, we found some of these statistics to be surprising.

Here’s what we found… during the 5-year period (2005-2009), there were a total of 481 fatalities. This averages to about 96.2 fatalities per year (or 1.85 fatalities per week). If you carry this logic forward, it equates to 1 fatality about every 4 days. And keep in mind that this data only covers incidents with at least one fatality or death, so these numbers don’t include all of those incidents that resulted in serious injuries or illnesses.

These fatalities occurred in 28 states…with just about every age group other than the very young and the very old equally represented. Over 61% (or 298) of these incidents occurred during construction, repairing or cleaning activities. For 203 of the fatalities, the victim worked in the construction industry regularly; however, 17% (or 83) of the victims were in management positions.

Over 61% of confined space entry fatalities occurred during construction, repairing or cleaning activities.

One of the most surprising statistics had to do with the causes of these fatalities. Generally, you would assume that the most common cause of confined space emergencieswould be atmospheric hazards. However, during this particular period, that was not the case. The largest cause by a significant measure was “Physical Hazards.” This broad term encompasses a lot of territory including, “struck by”; “caught in”; “collapses”; and “falls.” Physical hazards accounted for 294 or 61% of the fatalities. Atmospheric hazards (including fires) accounted for 160 or 33% of the incidents.

These numbers serve to remind us how important proper safety precautions are when it comes to confined spaces. For emergency responders, atmospheric hazards are always on our minds – however, from this, we also must consider the many physical hazards that are often found in confined spaces – especially when construction or maintenance activities are in process.
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Is relying on my local fire department in compliance with OSHA 1910.146?

Tuesday, September 13, 2011

Often the question comes up about using a local fire department for confined space rescue coverage in an industrial facility; and if it would be in compliance with OSHA 1910.146? In addition to the proper evaluation of the prospective rescue service, we always stress the need for “reciprocal communications” between the rescue service and the employer. For example, if the rescue service becomes unavailable at any time during a PRCS entry, the rescue service agrees to contact the employer so that the entry can be immediately suspended until the rescue service is once again available to respond in a timely manner.


The following is from an OSHA Letter of Interpretation dated 5/23/08.

Scenario: An employer evaluates and selects a local fire department using the guidance provided in Appendix F of the PRCS standard, Rescue Team or Rescue Service Evaluation Criteria (Non- mandatory). The employer has determined that the local fire department is adequately trained and equipped to perform permit space rescues of the kind needed at the facility. The employer has also made a performance evaluation of the service in which the employer has measured the performance of the team or service during an actual or practice rescue. However, the local fire department cannot guarantee that the rescue team will not be sent on another call during the employer’s permit-space entry operations. In other words, they have the ability to respond in a timely basis, unless another call prevents them from doing so.

Question: If the employer selects this local fire department as its off-site rescue service, would the employer be in compliance with 1910.146(k)(1)?

29 CFR 1910.146(k)(1) provides:

(1) An employer who designates rescue and emergency services, pursuant to paragraph (d)(9) of his section, shall:

(i) Evaluate a prospective rescuer’s ability to respond to a rescue summons in a timely manner, considering the hazard(s) identified;

Note to paragraph (k)(1)(i): What will be considered timely will vary according to the specific hazards involved in each entry. For example, 1910.134, Respiratory Protection, requires that employers provide a standby person or persons capable of immediate action to rescue employee(s) wearing respiratory protection while in work areas defined as IDLH atmospheres.

(ii) Evaluate a prospective rescue service’s ability, in terms of proficiency with rescue-related tasks and equipment, to function appropriately while rescuing entrants from the particular permit space or types of permit spaces identified;

(iii) Select a rescue team or service from those evaluated that:

(A) Has the capability to reach the victim(s) within a time frame that is appropriate for the permit space hazard(s) identified;

(B) Is equipped for and proficient in performing the needed rescue services;

(iv) Inform each rescue team or service of the hazards they may confront when called on to perform rescue at the site; and

(v) Provide the rescue team or service selected with access to all permit spaces from which rescue may be necessary so that the rescue service can develop appropriate rescue plans and practice rescue operations.

Note to paragraph (k)(1): Non-mandatory appendix F contains examples of criteria which employers can use in evaluating prospective rescuers as required by paragraph (k)(1) of this section.

The employer must evaluate and select an off-site rescue service that has the capability to respond in a timely manner to the particular hazards at issue and to the types of emergencies that may arise in the employer’s confined spaces. The criteria employers can use in evaluating and selecting a service include determining whether the service is unavailable at certain times of the day or in certain situations, the likelihood that key personnel of the rescue service might be unavailable at times, and, if the rescue service becomes unavailable while an entry is underway, whether the service has the capability of notifying the employer so that the employer can instruct the attendant to abort the entry immediately.

Compliance may require the employer to be in communication with the off-site rescue service prior to each permit space entry. In the scenario described, the employer must ensure close communication with the rescue service during entry operations so that if the rescue service becomes unavailable while an entry is underway, the employer can instruct the attendant to abort the entry immediately. Entry operations cannot resume until the entry supervisor verifies that the rescue service is once again able to respond in a timely manner.

ROCO COMMENTS:

It’s important to note that the off-site service must be willing to perform rescues at the employer’s workplace. As referenced in Appendix F (5)… For off-site services, is the service willing to perform rescues at the employer’s workplace? (An employer may not rely on a rescuer who declines, for whatever reason, to provide rescue services.)

Also, while a written agreement with the local agency is not necessarily required by the regulation, it certainly would make it easier to document that an agreement to respond was in place – and that the department had an understanding of the scope of services to be provided at the employer’s site (i.e., confined space rescue).
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Confined Space Fatality Follow-up

Monday, August 29, 2011

Here’s a follow up to a Confined Space Fatality story we published earlier this year. One of the injured persons (a “would be” rescuer and co-worker of the initial victim) remains hospitalized since January. According to a Cal/OSHA Chief, “it is unfortunately common for other employees to be injured or killed while attempting impromptu rescue of the initial victim.” In fact, NIOSH states that prior to enactment of the permit-required confined space regulation, 60% of all fatalities in confined space incidents where multiple fatalities occurred were “would-be” rescuers.

This article also addresses the importance of proper planning for confined space operations. These incidents continue to happen all too often when workers aren’t properly trained to deal with the hazards of confined spaces and the appropriate actions to take prior to entering a space – especially if a co-worker is already down. Keep in mind, most likely, there’s something very wrong in the space! As a rescuer, or a “would be” rescuer/co-worker, don’t rush into a confined space. You must protect yourself first!

Cal/OSHA fines prominent pharmaceutical firm $371,000 for safety violations leading to worker fatality

Los Angeles – Cal/OSHA issued eleven citations totaling $371,250 to Baxter Healthcare Corporation dba Baxter Bioscience this week for deliberate and willful workplace safety violations which resulted in the death of one of their technicians and serious injury of two others. The violations included four willful citations, indicating intentional violation or knowledge of a violation. Baxter has 15 business days to appeal or pay the citations. “We will not tolerate employers who intentionally sacrifice the safety of their workers,” said DIR Acting Director Christine Baker. “Our goal is to prevent these needless tragedies and ensure employers live up to their responsibility of protecting their workers.”

On January 21, Baxter technician Henry Astilla, 33, collapsed when he entered a seven foot deep, 6,000 liter tank in which nitrogen gas was being bubbled through plasma as part of a protein extraction process. Air in the tank had been displaced by the nitrogen gas resulting in an oxygen deficient atmosphere in the tank. Cal/OSHA regulations require employers to have special protective procedures in place prior to the entrance by employees into these types of confined spaces. In this case, the employer had not tested the atmosphere prior to entrance to insure there was sufficient oxygen, which led to Astilla’s death.

Cal OSHA’s investigation further revealed that when Astilla was discovered, a supervisor ordered two other employees to enter the tank and retrieve him, without testing the atmosphere of the tank or providing proper equipment and other safeguards necessary for a safe rescue. As a result, Astilla died and the two employees sent to retrieve him were seriously injured. One remains hospitalized since January.

“The hazards of working in confined spaces are well documented and this is a classic example of the kind of injury that occurs when employers fail to adequately protect their employees,” said Cal/OSHA Chief Ellen Widess. “When confined space operations are not properly planned, it is unfortunately common for other employees to be injured or killed while attempting impromptu rescue of the initial victim.”

Cal/OSHA determined that Baxter’s confined space program failed to comply with all requirements, including appropriate atmospheric testing, protective equipment as well as rescue equipment and procedures. Baxter Bioscience is a multi-national pharmaceutical company with a Los Angeles plant located in Atwater Village. The facility is the largest of its kind in the nation, utilizing advanced technology to produce plasma proteins.

The citations Cal/OSHA issued this week included one classified as general and ten classified as serious, four of which were classified as willful. Willful classifications are issued when an employer either commits an intentional violation and is aware that it violates a safety law, or when an employer is aware that an unsafe or hazardous condition exists and makes no reasonable effort to eliminate the hazard.
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